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WHITEHOUSE HOTEL LTD. PARTNERSHIP v. C.I.R.

No. 13-60131.

755 F.3d 236 (2014)

WHITEHOUSE HOTEL LIMITED PARTNERSHIP; QHR Holdings — New Orleans Limited, Tax Matters Partner, Petitioners-Appellants v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

June 11, 2014.

Attorney(s) appearing for the Case

Gary J. Elkins , Thomas Matthew Beh , Counsel, Yvonne Chalker, Elkins, P.L.C., New Orleans, LA, for Petitioner-Appellants.

Bethany Buck Hauser, Esq. , Kenneth L. Greene, Esq. , Supervisory Attorney, Kathryn Keneally , U.S. Department of Justice, Robert R. Di Trolio , U.S. Tax Court, William J. Wilkins , Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Elizabeth Sherrill Merritt, Esq. , Deputy General Counsel, National Trust for Historic Preservation, Washington, DC, Amicus Curiae.

Before STEWART, Chief Judge, and GARZA and SOUTHWICK, Circuit Judges.

LESLIE H. SOUTHWICK, Circuit Judge:

This appeal marks the second time Whitehouse Hotel Limited Partnership appeals from a ruling of the United States Tax Court disallowing a significant portion of a tax deduction claimed for a historic conservation easement. Whitehouse also appeals the tax court's enforcement of a 40 percent gross overstatement penalty. We AFFIRM the determination of the amount of the deduction but VACATE the penalty.

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